FAA Guidance Adds FRS Personnel Licensing Requirements
September 17, 2026
The FAA has issued a change to Order 8900.1 implementing the foreign repair station personnel licensing requirements of the 2024 FAA Reauthorization Law. Sec. 302 directed the FAA to require supervisory personnel and personnel authorized to approve an article for return to service to be certificated under 14 CFR part 65 as either a mechanic or repairman.
There have as of yet been no changes to the rules in either parts 65 or 145, meaning the official compliance requirements for repair stations located outside the United States have not changed. Updates to the agency’s guidance reflects the focus and interest of inspectors, which must be considered by certificate holders responsible for complying with 14 CFR and not the statements in FSIMS.
The change to 8900.1 appears in Volume 2, Chapter 11, Section 10, which addresses issuing, renewing, and amending repair station certificates for facilities outside of the territories of the United States in countries that do not have bilateral aviation safety agreements with maintenance implementation procedures with the FAA. The change adds a new section E to paragraph 2-1332. Consistent with a solution proposed by ARSA, the Aircraft Electronics Association, Airlines for America, the part 65 licensing requirement does not apply if the personnel hold certificates issued by a “foreign aviation authority whose licensing system has been determined by the FAA to be equivalent, based on standards consistent with the International Civil Aviation Organization (ICAO) Annex 1, Personnel Licensing, and applicable provisions of Annex 6.” To ARSA’s knowledge, the FAA has not published a list of those countries, but ICAO states that, “Each individual Contracting State should have the information available as they have the duty to inform ICAO of any difference between ICAO licensing Standards and their national/regional regulations. Any information in this matter submitted by Contracting States to ICAO is contained on the Supplement to Annex 1.”
The change to Order 8900.1 also states repair stations must also ensure the personnel in question (whether licensed by the FAA or a foreign authority) have the following minimum qualifications:
- Supervisory personnel and individuals directly in charge of maintenance functions: A minimum of 18 months of practical experience in the work being performed or training in or thorough familiarity with the methods, techniques, practices, aids, equipment, and tools used to perform the maintenance, preventive maintenance, or alterations. Ability to understand, read, and write English.
- Personnel authorized to approve articles for return to service: Appropriate training or at least 18 months of relevant practical experience, thorough familiarity with applicable regulations, and proficiency the inspection methods, techniques, practices, aids, equipment, and tools appropriate to the work being performed and approved for return to service.
The amendment comes on the heels of issuance of FAA InFO 26012, which addresses reporting requirements (also created by Sec. 302 of the recent FAA law) for U.S. air carriers that use foreign repair stations.
Previous foreign repair station updates...
9/18/08 - ARSA to Capitol Hill: New Foreign Repair Stations Integral to Industry
August 18, 2008
On July 8, 2008 an ARSA-led coalition of aviation industry representatives sent a letter urging Members of Congress to prevent the industry from suffering punishment due to inaction by the Transportation Security Administration (TSA).
Section 1616 of the “9/11 Commission Recommendation Act of 2007” (P.L. 110-53) and Sec. 611 of VISION 100 (the 2003 Federal Aviation Administration (FAA) reauthorization law) (P.L. 108-176) required the TSA to promulgate repair station security rules. Under those laws, if the TSA does not issue a final rule by Aug. 3, 2008, the FAA will be prohibited from issuing new certificates to foreign repair stations. Although there is an exception for certificate renewals and applications in process, the law will have unintended and negative consequences for U.S. companies seeking to expand operations overseas.
On May 13, TSA Administrator Kip Hawley testified before the Senate Commerce, Science and Transportation Committee that a final rule will not be issued by the Aug. 3, 2008 deadline. Indeed, it appears that the TSA will be hard pressed to issue a Notice of Proposed Rulemaking by that date.
Presented with this fact, ARSA turned its attention to Capitol Hill and, via the letter, sought to bring attention to the punishment looming over the aviation industry. The letter emphasized the important role of foreign repair stations in all aspects of the aviation industry, underscoring the fact that a freeze on foreign repair stations will create negative effects on the aviation community in the U.S. In addition, the letter questioned the logic of punishing private industry for the failings of a government agency.
This letter follows one previously sent by ARSA to TSA Administrator Kip Hawley exhorting the agency to meet the deadline for the final rule.
ARSA thanks those organizations lending support to this effort.
To read the July 8 letter click here.
1/20/07 - ARSA Testifies on Foreign Repair Stations
January 20, 2007
ARSA Managing Director and General Counsel Marshall Filler testified before the Aviation Subcommittee of the Senate Committee on Commerce, Science, and Transportation on June 20, 2007.
The hearing, entitled “Oversight of Foreign Aviation Repair Stations,” focused on the expanding role of international contract maintenance and the capabilities of the Federal Aviation Administration (FAA) to ensure oversight of foreign entities. In addition, the hearing discussed work being completed by so-called “non-certificated repair stations”, both foreign and domestic.
The hearing resulted, in part, from ARSA’s successful efforts to defeat proposed language in the FAA reauthorization bill (S. 1300) that would have mandated drug and alcohol testing of all domestic and foreign repair station employees, and imposed new restrictions on the use of contract maintenance by air carriers.
Other witnesses at the hearing were The Honorable Calvin L. Scovel III, Inspector General, U.S. Department of Transportation, Peggy Gilligan, Deputy Associate Administrator for Aviation Safety, U.S. Department of Transportation, Robert Roach Jr., General Vice President, The International Association of Machinists and Aerospace Workers, Basil Barimo, Vice President of Operations and Safety, Air Transport Association and Tom Brantley, President, Professional Airway Systems Specialists.
Mr. Filler’s written testimony is available here.
There are multiple posts and issue pages covering foreign repair station issues. To search ARSA.org, click here and also be sure to check arsa.org/faa-reauthorization-2024 and arsa.org/drugandalcohol.
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